– KPA CONFIDENTIAL –

Recordkeeping 101: EPA and OSHA Required Paperwork

Thank you for joining the webinar. We will begin at 10am Mountain Standard Time.

– KPA CONFIDENTIAL –

Recordkeeping 101: EPA and OSHA Required Paperwork

Thank you for joining the webinar. We will begin at 10am Mountain Standard Time.

PresenterPresenter

Nick Bujeaud District Manager (860) 995-8023 nbujeaud@kpaonline.com

QuestionsQuestions

• If you have questions during the presentation, please submit them using the “Questions” feature

• Questions will be answered at the end of the webinar

KPA – Company ProfileKPA – Company Profile

• Nationwide compliance expert on Safety, Environmental, HR

• Colorado Headquarters

• 23 Years Experience • 3000 + Clients

– Dealerships, Service, Repair

• 20 Offices Serving 41 States

• Compliance products and services

– OSHA– DOT– EPA– Workers’ Comp– Background checking– Onboarding– Harassment – Red Flags– Onsite inspections– Online and onsite

training and tracking– And many more…

So you think you’re covered?So you think you’re covered?

– KPA CONFIDENTIAL –

This Week’s HeadlinesThis Week’s Headlines

“US Department of Labor's OSHA takes action to protect America‘s workers with severe violator program and increased penalties”

“US Department of Labor's OSHA proposes nearly $136,000 in penalties against Sewon America Inc. for willful and serious safety violations”

FAA proposes $53,000 fine against Stewart & Stevenson, LLC for shipping a box containing touch-up paint to FedEx Corp. for transportation by air...

“Nebraska firm pays $150,000 fine for waste problems”

“EPA fines Iowa battery maker over pollution”

OutlineOutline

• Training

• Best Management Practices

– KPA CONFIDENTIAL –

EPAEPA

• Waste Determinations*- Current

• Waste Manifests- 3 years

- 2 year bill of lading- Copy #6, Copy #3

– KPA CONFIDENTIAL –

10

EPAEPA

– KPA CONFIDENTIAL –

DOT HazMat Training Needed

Hazardous Waste Training Needed

EPAEPA

– KPA CONFIDENTIAL –

Refrigerant Recovery and Recycling609 AC Folder, to include:- Technician Certifications- Equipment Registrations- Refrigerant Purchasing Records

EPAEPA

– KPA CONFIDENTIAL –

Spill Prevention, Control, and Countermeasures Plan (SPCCP)

A facility starting operation…  Must...

On or before August 16, 2002

Continue to maintain its existing SPCC Plan in accordance with the SPCC rule. Amend and implement that Plan no later than November 10, 2010

After August 16, 2002, through November 10, 2010

Prepare and implement an SPCC Plan no later than November 10, 2010

After November 10, 2010

Prepare and implement an SPCC Plan before beginning operations

Fact Sheets

- New Plan when elements of the Plan change- 5 year re-certification- Tank Inspections, monthly

EPAEPA

• USTA. Corrosion Prevention

B. Leak Detection*C. Financial Responsibility*D. Closure Records

• Tier II: greater than 10,000 lbs. of storage, annual submission, due by March 1

Gasoline: 1,600 gal.Diesel Fuel: 1,399 gal.Battery Acid: approx. 100 used batteriesFuel Oil: 1,282 gal.Antifreeze: 1,111 gal.Motor Oil: 1,389 gal.

– KPA CONFIDENTIAL –

EPA’S NEW 6H RULESEPA’S NEW 6H RULES

• Notification• 1/11/2010

• Painter Training • Spray Gun Selection • Spray Gun Cleaning• Spray Booths• Re-Notification

• 3/11/2011

• Recordkeeping• Mobile Operations

OSHAOSHA

• Hazard Communication PlanWritten Plan, current

Chemical Inventory, annual update + 30 year archiveMSDS, current, accessed in under 10 minutes

– KPA CONFIDENTIAL –

OSHAOSHA

• Emergency Response Plancurrent, updated as changes occur

- Fire Response- Spill Response- Natural Disasters

– KPA CONFIDENTIAL –

OSHAOSHA

– KPA CONFIDENTIAL –

Hazard Assessment/ PPE Selection*- current- updated as new hazards are introduced to the work area

OSHAOSHA

• Respiratory Protection ProgramWritten Program, current

Respirator Change-Out logAppendix D for Voluntary use, 1 time per employee, per respiratorFit-Test Records, current and required annuallyMedical Evaluations*, 30 years after employment

– KPA CONFIDENTIAL –

OSHAOSHA

• ForkliftWritten Program, current

Employee Certification, 3 yearsDaily Inspection

OSHAOSHA

• OSHA logs (SIC 5500 exempt)301: Not Required

300: Current

300A: Post from February 1 through April 30 for the previous year

• InspectionsFire Extinguishers*: Annual/ Monthly

First Aid Kits*: Monthly

Eye Wash Stations*: Monthly

Facility Hazards*: Regularly

– KPA CONFIDENTIAL –

TrainingTraining

• Emergency Response- ALL employees- Upon initial employment and annual refresher- Archive current only

• Hazard Communication- EEs exposed to hazardous chemicals- Upon initial assignment and again when a new hazard in introduced- Archive current only

• PPE- EEs required to use PPE- Upon initial assignment and when changes occur- Archive current only

• Forklift- Forklift Operators upon initial assignment, when an incident occurs, and 3 yr refresher- Archive current only

– KPA CONFIDENTIAL –

TrainingTraining

– KPA CONFIDENTIAL –

• DOT Hazardous Materials- Haz Mat employees- Within 90 days of initial assignment if shipments are directly supervised by someone trained, refreshed every 3 years- Archive for 90 days after employment ends

• Respiratory Protection- EEs required to use a respirator- Upon initial assignment, when changes occur, and annual refresher- Archive current only

• Respirator Fit-Testing- EEs using a tight fitting respirator - Upon initial assignment and refreshed annually- Archive current only

TrainingTraining

• Forklift- Forklift Operators- Upon initial assignment, whenever an incident occurs, and 3 year refresher- Archive current only

• Hazardous Waste Management- EEs of Small Quantity Generators (SQGs) of hazardous waste handling, storing, or managing hazardous waste- Upon initial assignment and annual refresher- Archive current only

– KPA CONFIDENTIAL –

Best Management PracticesBest Management Practices

• Hiring process to include all EHS training in new EE orientation

• Centralize and organize all documents in Business Office or HR Department

- Organize waste streams by type, group by year- Keep all training records behind an updated EE list with hire dates- Break down other folders by category discussed here: 609 AC, SPCCP,

UST, written programs, etc.

• Retain a copy of anything mailed to a regulatory agency and attach a certified mail receipt

– KPA CONFIDENTIAL –

BMPsBMPs

• Clearly identify responsibility and empower that employee

• Internal Audit Schedule

• Obtain Certificates of Insurance for all outside contractors

• Seek counsel from EHS Professionals and attorneys in your area!

– KPA CONFIDENTIAL –

Nick’s “Do it Now” Top 5Nick’s “Do it Now” Top 5

1. If you have over 1,320 gallons of petroleum, start on that SPCCP!

2. Hazard Assessment and PPE Selection/Provision!

3. Employee Training!

4. Organize all these documents in 1 central location! Empower someone at your facility to be responsible for this stuff!

5. Obtain certificates of insurance for all outside contractors!

– KPA CONFIDENTIAL –

Questions and AnswersQuestions and Answers

– KPA CONFIDENTIAL –

QUESTIONS?

Contact InformationContact Information

– KPA CONFIDENTIAL –

The recorded webinar and presentation slides will be emailed to you today including your local representative’s contact information.

www.kpaonline.com

bross@kpaonline.com

866-288-8765